EVOLVING US SANCTIONS: MAINTAINING COMPLIANCE

R&C: Could you provide an overview of the main trends and developments across the US sanctions landscape over the past 12 to 18 months? How would you characterise the scope of sanctions activity under the Trump administration?

Parfitt: It was never going to be easy to predict how the arrival of president Trump would affect sanctions policy. And in the light of recent decisions, the future still looks uncertain. But has very much changed since the Obama administration? Despite swings between bellicose rhetoric and encouraging moves toward dialogue with North Korea, for example, realistically nothing has changed there in the last year. US sanctions continue to bite and continue to be issued. The biggest potential development in the US sanctions landscape in recent months is undoubtedly president Trump’s decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), a move that could potentially have far-reaching consequences not just for the US and Iran, but also for the rest of the world. In a tweet posted 7 August 2018 Trump said: “These are the most biting sanctions ever imposed, and in November they ratchet up to yet another level. Anyone doing business with Iran will NOT be doing business with the United States. I am asking for WORLD PEACE, nothing less!” However, with global powers including the European Union condemning the US withdrawal from the JCPOA and actively encouraging their members to ignore US threats, there is a danger that the president’s desire to go it alone and appear strong at all costs has to some extent devalued the power of the US sanction.